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An existing Q&A document for NRA implementation can be downloaded,
and new questions are answered below.
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How do I add a new question?Go to the "Quick Q+A" page and submit a question in the comment box.
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Will attendance at the 2022 CW Regional Meetings will be required for all FSC Certificate Holders with Controlled Wood in scope for their certificate?No. The expectations for certificate holders (CH) are the same as in 2018. If a CH is sourcing materials that they wish to control from a specified risk area defined in the US NRA and is implementing a mandatory control measure from the US NRA, they may attend the meeting or send a representative or simply review the associated report and demonstrate that they are knowledgeable of the meeting outcomes. CH that are not sourcing materials that they wish to control from a specified risk area and/or are not implementing a mandatory control measure are not required to do any of the above related to the CW Regional Meetings.
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Does participating in the November 22 webinar count as attendance in the regional meeting?No. The purpose of the webinar is to provide a common understanding of why the 2022 Controlled Wood Regional Meetings are being held, to answer questions about the informed consultative process, and to receive input that will help with organizing and structuring the regional meetings (i.e., help to make them more effective).
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Will the Controlled Wood Regional Meeting Reports be revised following the 2022 Regional Meetings?Yes, if this informed consultative process suggests that there is a need to revise the mitigation options. However, the timeline for a revision has not yet been determined. As the mitigation options within the Controlled Wood Regional Meeting Reports are considered a normative element of the US National Risk Assessment, we will need to coordinate the revision of the Controlled Wood Regional Meeting Reports with FSC International.
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Is there a cost for attending a Controlled Wood Regional Meeting?No. Coffee and lunch will be provided.
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Was the webinar recorded?Yes, a recording of the webinar is available from the "Home" page of this web site (below the "Step 2" content).
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Will there be an option to attend the Regional Meetings remotely, at least in part?No. The regional meeting will not have remote participation. This is because the engagements will predominantly utilize breakout discussions in small groups to further conversations and insights on key mitigation issues. That said, we will post meeting summaries on the 2022 Controlled Wood website for public access and comment. In addition, the pre-meeting webinar, interactive website, and ability to have direct responses from Amy to your queries and inputs will ensure your input is heard and part of this process. We understand that this approach may be difficult to understand for some, however our experience with offering a mix of remote / in-person participation results in not being able to accurately predict how many individuals will actively participate in the meetings, making logistics doubly difficult. We thank you for your understanding.
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How is effectiveness being measured using spatial data?FSC US has established a set of data that represent baseline conditions within the specified risk areas. We will be looking for long-term changes which indicate that the stated intent of the mitigation options is being achieved within the specified risk area, or at least within sub-areas of the specified risk area with more concentrated sourcing by FSC certificate holders. We are using both quantitative and qualitative data for this purpose. Use of spatial data is just one of the ways that we have established baseline conditions.
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There seems to be an underlying assumption that the mitigation format needs updating. Given the very incomplete effectiveness monitoring process, please explain why? How do we improve effectiveness without first assessing effectiveness?While we understand that determining effectiveness at a landscape scale is a long-term endeavor, FSC US is asking process participants to reflect on their experiences and knowledge gained thus far, in combination with what FSC US learned in the initial year of monitoring and evaluation and through our partnership with American Forest Foundation, to help identify adjustments in the mitigation options that can already be identified and made to increase effectiveness. This qualitative approach is being undertaken in part because the FSC US Board of Directors committed to re-visiting the mitigation options through a second round of Controlled Wood Regional Meetings a couple of years into implementation of the unique US Controlled Wood system to assess at a coarse level how things were going and to make adjustments as needed and possible.
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What are we measuring and what change are we supposed to be seeing?At the scale of the Controlled Wood system in the US as a whole, the objective of FSC US’s monitoring and evaluation framework is to 1) provide evidence that the risk of sourcing unacceptable materials is decreasing within each specified risk area, and 2) gather monitoring data to evaluate the program’s effectiveness in producing on-the- ground changes in forest management. At the scale of an individual specified risk area and the mitigation activities being implemented, effectiveness should be evaluated as to whether it is or is likely to be achieving the intent of the mitigation option, as described in the applicable Controlled Wood Regional Meeting Report.
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Providing a standardized template for education and outreach would make this more effective. If individuals are receiving different materials or facts, this could be problematic. Is there a way that these materials could be provided?Maybe. At the time that the mitigation options were originally being developed, the FSC US Board of Directors indicated that they would like FSC US to help provide education materials, as possible. Unfortunately, limited time and resources and other higher priorities have not made this possible, as of yet. However, as FSC US looks forward to 2023 and identifies priorities that will help us to achieve our strategic objectives, these activities will be re-assessed.
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Would funding a company that is planting trees count as a conservation initiative?It depends. If this action is aligned with a mitigation option for the applicable specified risk area, and would achieve the intent of the mitigation option (as described in the applicable Controlled Wood Regional Meeting Report), then yes, it should count as implementation of that mitigation option.
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What is happening with the partnership between AFF and FSC?American Forest Foundation (AFF) and FSC US successfully completed the project that we defined for this partnership in 2021. As part of this project, AFF used their expertise and landowner networks to characterize family forestland ownership in pilot areas, and helped FSC US assess which ownership groups are most critical. Additionally, AFF utilized their strong relationships and familiarity with the United States Forest Service (USFS) Forest Inventory & Analysis (FIA) systems to curate data and develop a framework for using the vast FIA datasets for FSC US’s monitoring and evaluation efforts. Finally, AFF examined the potential impact of the outreach and education mitigation efforts within these pilot regions and made suggestions for improvements. AFF has recently gone through an extensive strategic planning process and has subsequently shifted their long-term goals and objectives. As a result of this shift, AFF has determined that direct support of FSC US’s monitoring efforts is no longer aligned with their strategic direction. However, they are willing to share the methodologies that they have used and FSC US will be looking for other partners with whom we can work to implement them in additional areas in the coming years.
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You (FSC US) seem to have a lot of information from your early monitoring effort that has not been shared with the community. Is there a reason why we don’t have a detailed summary of what you have learned so far?Yes – staff capacity. The staff member who was lead on the monitoring and evaluation efforts left FSC US for another opportunity earlier this year. He completed the reporting to FSC International for Year 1 to which we had committed, but did not finalize a public report of our efforts before leaving. Due to the current severe staffing shortage at FSC US, remaining staff had to prioritize other items and have not yet completed this public report. We are anticipating an increase in staff in early 2023 and will work to finalize and share the report. A summary of the monitoring and evaluation efforts is available through the website for this process, including top-line findings.
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What does FSC US want practitioners to bring to the regional meetings in December?Bring your experiences, observations, and knowledge regarding Controlled Wood in the US. Be able to articulate what you think is going well, and not so well. Identify your personal highest priority concerns, your ideas for addressing these concerns, and help us ensure that both are considered during this process. Bring a willingness to listen, to share, and to discuss in a respectful manner.
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ASI has been completing Compliance Audits in the US this year. They have been bringing their own interpretation as to what is deemed sufficient within the US NRA. This has created significant uncertainty about CW is the US and North America in general. A simple interpretation from ASI has the effect of up-ending the whole system. Certificate holders cannot deal with uncertainty like this. Is this being addressed?Yes. FSC US is engaged with FSC International on this issue. Our understanding is that ASI’s key technical issue had to do with the language of the advice note (ADVICE-40-005-24) which was intended to remove the responsibility for certificate holders to demonstrate the effectiveness of their actions at a landscape scale, and place this responsibility on FSC US instead. FSC International indicated their intention to work with FSC US on a revision of the Advice Note. Additionally, the FSC International staff recognized that revision of the FSC Controlled Wood Standard (FSC-STD-40-005) is anticipated to begin in 2023, and indicated that it is their intent to ensure that following revision, the standard will be feasible for all certificate holders, and that the US advice note will no longer be necessary. We will need extensive participation in this revision process from US stakeholders to help make sure that this actually happens.
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How long do we think the CW standard revision might last?It depends. The process will likely take 2-3 years to complete, but the actual length will depend on the extent of changes that are considered by the Working Group. At the beginning of the process, a “Review Report” on the Controlled Wood Standard (FSC-STD-40-005) will be shared for public consultation, which defines the issues that FSC proposes be considered as part of the revision. The consultation will invite comment on those issues, and stakeholders will also be able to identify additional issues that they believe should also be considered. Based on the input received during this consultation, FSC will develop a timeline for the revision process.
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So, after the regional meetings, FSC US will engage with FSC International to decide whether to formally revise the mitigation options immediately, or wait to do it at the same time as the NRA revision. What considerations would influence that decision to move forward or wait? What factors would you raise around the tradeoffs?FSC International considers the mitigation options to be a normative element associated with the US NRA, and FSC International must approve our proposal to revise the NRA (or the mitigation options) before we begin a formal process to do so. Likely, the most significant considerations will be whether, through this informed consultative process including the regional meetings, FSC US identifies significant changes that would improve the effectiveness and/or feasibility of the mitigation options. If no potential changes are identified, or if proposed changes are minor in nature, then FSC US would likely recommend delaying any revisions to the mitigation options. However, if an opportunity to significantly improve either effectiveness or feasibility is identified, FSC US would likely recommend a more immediate revision process. In terms of tradeoffs, the most likely would be the burden of asking certificate holders to make adjustments, vs. lost opportunity if the adjustments are not made. Note that FSC US has been asked to delay revision of the NRA until after the revision of the NRA Framework document (FSC-PRO-60-002a) has been completed. Therefore, we anticipate that the US NRA revision will not begin until 2024.
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You (FSC US) signaled the importance of US certificate holders involvement in the NRA framework consultation. What do you think is most salient to weigh in around, given the US landscape and how our supply chains work, data availability, etc.?FSC US encourages all engaged stakeholders to participate in the ongoing public consultation of the NRA Framework (FSC-PRO-60-002a). We understand that a more structured approach to developing risk determinations is being proposed, and we encourage stakeholders to consider the feasibility and effectiveness of this approach at the scale of the United States, considering potential availability and granularity of applicable data/information. Stakeholders may participate in the public consultation through December 15, 2022 via the FSC Consultation Platform (https://consultation-platform.fsc.org ).
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